Regs in Space

The 30-year US space shuttle program is drawing to a close. The final shuttle launch is scheduled for June 28, when Atlantis is slated to embark on its last voyage.  The last launch is likely to attract more people than this one, estimates run one million and up. 

This blogger intends to watch. Respect, Salute, Cheers. Perhaps every engineer in my age group owes part of their passion to the inspiring space program of the late 60s.

Programs focusing on humans in space now belong to other countries.  But the aerospace industry still booms at home.

Regs in aerospace. From a regulatory standpoint, the aerospace industry is a unique beast.  In 2005, the FAA published “Aviation and Emissions, a primer,” which was largely about the flight and emissions.  More a logistics concern at the time, it’s worth reminding ourselves that this modern era of manufacturing considers waste and downstream emissions reporting in design, supply and build phases.

On February 3, the Office of Management and Budget approved the Section 114 Information Collection Request (ICR) for the aerospace manufacturing and rework industry.

For more on managing compliance with emissions standards, Actio technology can help, or try reviewing EPA documents such as Risk & Technology Review.  Hazardous Air Pollutants or HAPs are a key component of related emissions reports.

In term of pending deadlines, it’s worth noting that by May 4, Major and Synthetic Minor sources must supply all remaining data on the ICR (see Allowable Forms).

Electronic components as exemption. So what is the definition of electronic components for the purposes of completing the information collection request (ICR) for the aerospace source category?  The aerospace rule provided an exemption for electronic components but it did not provide a definition or guidance for “electronic component”.

EPA suggests using common sense on what constitutes an electronic component.  (We’d all like to believe this will work!)

“If you have a solid justification, that any reasonable person would accept, for the part or component being an electronic component then please do not report the activities associated with that part or component on the ICR,” says EPA.  “However, if you question whether or not it would be considered an electronic component then you should report the activities associated with that part or component.”

Docket, Federal Register and National Emissions Standards. There are three key rivers that merge in a delta to form a gulf of aersospace emissions standards.

The Docket: Air and Radiation Docket The Air and Radiation Docket and Information Center (The Docket) contains information on Air and Radiation rules and proposed rules. The Docket is composed of Federal Register Notices, the rules, and supporting documentation, and public comments.

The federal register states that the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Aerospace Manufacturing and Rework Facilities were proposed on June 6, 1994, and promulgated on September 1, 1995.

National Emission Standards applies to owners and operators of new, reconstructed, and existing aerospace manufacturing and rework facilities where the total hazardous air pollutants (HAP) emitted are greater than or equal to 10 tons per year of any one HAP; or where the total HAP emitted are greater than or equal to 25 tons per year of any combination of HAP.

Operations covered include such activities as:

  1. cleaning
  2. primer and top coat application
  3. depainting
  4. chemical milling maskant application
  5. handling and storage of waste.

The information is to be used by enforcement agencies to verify that sources subject to the standard are meeting the emission reductions mandated by the Clean Air Act.  Owners and operators of aerospace manufacturing and rework facilities are required to submit initial notification, performance tests, and periodic reports.

Aersopace manufacturing, being largely for military purposes, is often exempt from industry standards and regulations.  However, often companies have their own lists, because tracking chemicals is critical even if there really were “No Rules.”  Thus, many custom lists of chemicals apply in aerospace manufacturing and supplier compliance.  Boeing and Lockheed attend their own hazardous substance lists, for instance.  Then of course Canada, China and Europe have their own as well.  This litany of unique sets of parameters makes communications and disclosure practices for suppliers more complicated.

But that’s another subject for another day.  To find out more about streamlining supplier disclosure practices, examine the information at Material

Aerospace standards. Key standards organizations are SAE, RTCA, and EUROCAE.  Specifically, these originating organizations and ISO-recognized international aerospace standards include:

1. SAE AS 755 C
Aircraft Propulsion System Performance Station Designation and Nomenclature

/SAE AS 4893
Generic Open Architecture (GOA) Framework

/SAE MA 4872
Paint tripping of Commercial Aircraft – Evaluation of Materials and Process

/SAE ARP 4150
Procedure for Inspection of Inservice Airborne Accumulators for Corrosion and Damage

Software Consideration in Airborne Systems and Equipment Certification

Software Consideration in Airborne Systems and Equipment Certification (published in December 1992)

For more, see ISO.

Sacramento Protocol. The Sacramento Protocol is worth mentioning.  “Sacramento Protocol” Final Report of November 24, 1997 provides results of an effort by the California Air Resources Board (CARB or State), the EPA, and the South Coast Air Quality Management District (SCAQMD or District).  The joint effort sought to determine whether identified State and District air pollution control requirements in California are technically equivalent to the requirements found in five MACT standards, including the Aerospace NESHAP, and has bearing on emissions standards.  To download a copy, see EPA link here:

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About Kal

Kal Kawar, CIH, PE, has a bachelor's in chemical engineering and a master's in industrial hygiene. His professional experience includes serving as staff industrial hygienist for IBM's New York semiconductor manufacturing facility, and as industrial hygienist for IBM’s US headquarters. Now executive vice president of Actio, Kal taps more than 20 years' worth of chemical engineering, industrial hygiene, and environmental engineering experience. His far-reaching expertise with global regulatory challenges created by EPA, TSCA, REACH, RoHS, WEEE – and hundreds of others – aid in developing Actio software solutions for MSDS management, raw material disclosure compliance, and product stewardship in a supply chain.